State of Minnesota v. Rebecca Julie Malecha, 3 N.W.3d 566

Rebecca Julie Malecha was arrested by Faribault police on the basis of an arrest warrant that had already been quashed by the district court, though this was not reflected in law enforcement databases due to a clerical error by court administration.
During the arrest, officers conducted a search incident to arrest and discovered controlled substances on Malecha.
Following her arrest, it was confirmed that the warrant had in fact been quashed, but officers were acting on outdated information.
Malecha moved to suppress the evidence and dismiss the charges, arguing that the search was unconstitutional because it was made pursuant to an invalid warrant.
The district court granted the motion, concluding the exclusionary rule applied and that no good-faith exception excused the constitutional violation; the appellate court reversed, but the Minnesota Supreme Court reinstated the suppression, focusing on state constitutional grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the warrant quashed before Malecha’s arrest?	The warrant was quashed and thus arrest/search was unlawful.	No clear evidence warrant was quashed; arrest was on active warrant.	Warrant was quashed before arrest; factual finding upheld.
Should the exclusionary rule apply when police act on bad information due to a court error?	Yes, evidence must be excluded to deter government errors, not just police misconduct.	No, exclusionary rule is to deter police misconduct only; police acted in good faith.	Exclusionary rule applies; serves to deter unlawful government conduct generally.
Does the good-faith exception to the exclusionary rule cover these facts?	No, good-faith exception does not apply to reliance on court clerical errors under state constitution.	Yes, good-faith exception should excuse police acting on database info caused by court clerical error.	Good-faith exception does not apply in this scenario under Minnesota law.
Should Minnesota follow the federal (Evans) rule on court employee errors?	No, Minnesota Constitution can provide stronger protections than federal law.	Yes, exclusion should only deter police, and not court administration, mistakes.	Minnesota follows its own, more protective approach under state constitution.

State v. Lindquist, 869 N.W.2d 863 (Minn. 2015) (good-faith exception applies only in narrow circumstances where police rely on binding appellate precedent)
State v. Zanter, 535 N.W.2d 624 (Minn. 1995) (evidence suppressed for warrant not supported by probable cause, even if police acted in good faith)
Garza v. State, 632 N.W.2d 633 (Minn. 2001) (exclusionary rule applied despite police reliance on issued warrant because of insufficient particularized circumstances)
State v. Leonard, 943 N.W.2d 149 (Minn. 2020) (declined to extend good-faith exception beyond reliance on appellate precedent)
State v. Carter, 697 N.W.2d 199 (Minn. 2005) (Minnesota Constitution provides greater protections than the federal counterpart in some search/seizure contexts)
State v. Bernard, 859 N.W.2d 762 (Minn. 2015) (describing search incident to lawful arrest exception)